Terrorist Financing - Anti-Terrorism Advisory Council

Part of the United States Government's strategy against international terrorism involves attacking the financial support base of terrorism. This is accomplished by listing specific groups and persons based upon their proven terrorist activities or support of those activities and then prohibiting United States citizens and any other person subject to United States law from supporting those groups and persons. The Department of State designates "Foreign Terrorist Organizations," or "FTOs," and the Department of the Treasury designates "Specially Designated Nationals," or "SDNs." Contrary to a popular misconception, this designation process predates passage of the USA PATRIOT Act.

The FTO list was first established in 1997. Designation as an FTO is reviewed every two years, and is subject to judicial review in the U.S. Court of Appeals for the District of Columbia Circuit when an organization, or its would-be donors, wishes to challenge the designation. The criteria for designation as an FTO is that the group is a foreign organization that engages in terrorist activity that threatens the security of United States persons or the national security of the United States.

SDNs consist of "SDGTs" (Specially Designated Global Terrorists) and "SDTs" (Specially Designated Terrorists). This list is maintained by the Treasury Department's Office of Foreign Assets Control (OFAC), and it includes the State Department's FTO list. The difference between the State Department's FTO list and the Treasury Department's SDN list is that the SDN list includes individuals and is not limited to foreign organizations.

Persons who support or contribute to an FTO may be prosecuted for providing material support to an FTO in violation of Title 18, United States Code, Section 2339B. Knowingly giving to an SDN may result in violation of Title 50, United States Code, Sections 1701-07, and may also violate Title 18 material support prohibitions if the SDN is also an FTO.